Friday, January 2, 2015

Defendant “Antoine L. Freeman J.D. (Attorney at Law)” Cause No. 1:14-CV-592 “First Set of Interrogatories”

(9)

Explain in full expert Attorney at Law details, after you filed your “General Denial”

for the Co-Defendant(s) Joyce M. Guy and Edward McCray (herein) behalf collectively

to complaint Cause No. A-180805 in Jefferson County Texas on the dates of December 18th 2007

And your claiming in Document # 2 attached herein “Your response to Pro Se Plaintiff Motion for

sanction against you for violations of Rule 193.1 Texas Rules of Civil Procedure

by failing to respond to Plaintiff’s discovery request during the months of March of 2008,

April of 2008, May of 2008, June of 2008, July of 2008, August of 2008, September of 2008,

October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009,

May of 2009, June of 2009, July of 2009, August of 2009, and September of 2009 you did not file a “timely response”

And “Your” in full possession, custody and legal control over Pro Se Plaintiff Motion for Production of Documents

dated August 12th 2009 and you did not file a “timely response” to the Production of

said Property deeds and all records involving Hurricanes, Rita, Humberto,

and Ike, contractor estimates, insurances records;

and “Your in 1005 absolutely refused to file a immodestly motion for

your withdrawal as claiming your (Only) duties was the filing of the General Denial

as “Your” lingering on this civil action as acting “Attorney of Record for exactly

December 18th 2007- December 11th 2009

Explain in full expert “Attorney at Law” details, why..?

That said “Property”, dwelling, and deeds thereof

“for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)

Already being a physical issue of “material evidence”

subject matter and actual party thereof in a civil suit in Common law in the State of Texas

Since November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars

while you’re still acting “Attorney of Record” cause No A-180805

Throughout the time frame dates of December 18th 2007 throughout December 11th 2009

Legally end up in The “Texas Department of Housing & Community Affairs” being 1005 legally full possession,

custody control and legal affairs surround the actual transfer on June 18th 2009

Then “deeds” release on July 22nd 2013 and then “deeds’ terminated on July 22nd 2013 said possession,

custody and control of “Property Deeds, back into the possession, custody and legal control to the

Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively

On April 14th 2014 as described in Pro Se Plaintiff attached Document # 7 attached herein “Jefferson County Texas Property search Index” Instrument # 2014012455

When this “Property”, dwelling, and deeds thereof “already being a issue of “material evidence”

and actual party thereof in a Civil suit in Common law in the State of Texas

Since November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars while you’re still acting Attorney of Record…..?

(10)

Explain in full expert Attorney at Law details, after you filed your “General Denial” for the Co-Defendant(s) Joyce M. Guy and Edward McCray (herein)

behalf collectively to complaint Cause No. A-180805 in Jefferson County Texas on the dates of December 18th 2007

And your claiming in Document # 2 attached herein “Your response to Pro Se Plaintiff Motion for sanction against you

for violations of Rule 193.1 Texas Rules of Civil Procedure by failing to respond to Plaintiff’s discovery request during the months of

March of 2008, April of 2008, May of 2008, June of 2008, July of 2008, August of 2008, September of 2008,

October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009,

May of 2009, June of 2009, July of 2009, August of 2009, and September of 2009 you did not file a “timely response”

And “Your” in full possession, custody and legal control over Pro Se Plaintiff Motion for Production of Documents dated

August 12th 2009 and you did not file a “timely response” to the Production of said Property deeds and all records involving Hurricanes,

Rita, Humberto, and Ike, contractor estimates, insurances records; and “Your in 1005 absolutely refused to file a immodestly motion for

your withdrawal as claiming your (Only) duties was the filing of the General Denial as “Your”

lingering on this civil action as acting “Attorney of Record for exactly December 18th 2007- December 11th 2009

And said “Property”, dwelling, and deeds thereof “for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)

Already being a physical issue of “material evidence” subject matter and actual party thereof in a civil suit in Common law in the State of Texas

Since November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars while you’re still acting “Attorney of Record” cause No A-180805

Throughout the time frame dates of December 18th 2007 throughout December 11th 2009

Legally end up in The “Texas Department of Housing & Community Affairs” being 100% legally full possession,

custody, control and legal affairs thereof surround the actual transfer on June 18th 2009

Then said “deeds” release on July 22nd 2013 and then same said “deeds’ terminated on July 22nd 2013 said possession,

custody and control of “Property Deeds, back into the possession, custody and legal control to the

Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively

On April 14th 2014 as described in Pro Se Plaintiff attached Document # 7 attached herein

“Jefferson County Texas Property search Index” Instrument # 2014012455

When this “Property”, dwelling, and deeds thereof “already being a major issue of “material evidence”

and actual party thereof in a Civil suit in Common law in the State of Texas

Since November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars involving

Fraud surrounding Hurricanes “Rita, Humberto, and “Ike” as the Original Complaint A-180805,

U.S. Complaint and As being fully legally described before the “Honorable Justice” in this U. S. Cause 1:2014-CV-592 herein now

(11)

Explain in full expert “Attorney at Law” details, Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein

Fully why that “Your” legally involved in this dishonest, deceitful quite fraudulent bogus transfer of “property and deeds” thereof

And failing to disclosed “material facts” said “property and deeds thereof was in the custody, possession and

legal control of the “Texas Department of Housing & Community Affairs” as described in

Pro Se Plaintiff attached Document # 7 attached herein “Jefferson County Texas Property search Index” Instrument # 2014012455

While you’re still acting Attorney of Record in ongoing civil suit A-180805 58th Judicial District Court of Jefferson County Texas…..?

(12)

Further Explain in full expert “Attorney at Law” details, Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein

Fully why that “Your” being fully legally, and professional skilled “Attorney at Law” aware of the facts that

the Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively being fully 100% involved,

engaged in this dishonest, deceitful quite fraudulent bogus transfer of “property and deeds” thereof

for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)

And failing to disclosed this “material facts” said “property and deeds thereof was in the full physical custody,

possession, and legal control of the “Texas Department of Housing & Community Affairs” for a $76,000.00 U.S. Dollars Housing Grant

As described in Pro Se Plaintiff attached Document # 7 attached herein “Jefferson County Texas Property search Index” Instrument # 2014012455

While you’re still acting Attorney of Record in this ongoing civil suit A-180805 in the 58th Judicial District Court of Jefferson County Texas dated November 26th 2007…..?

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